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CMS 2014 CEHRT Flexibility Rule
Implementation in Tennessee
By Cindy Wallace | TennCare | December 2014
Qsource HIT Consulting Services has operated as Tennessee’s
Regional Extension Center (REC) since 2010 assisting providers with
adopting electronic health records and attesting to meaningful use.
We work closely with TennCare to ensure providers have the
information they need to continue along the path improving patient
care.
We offer a broad range of services to include Meaningful Use
Assistance, HIPAA Compliance, Audit compliance, Patient
Engagement, and establishing Patient Portals
Visit us online at www.Qsource.org/HIT | Or call: 866-514-8595
CMS 2014 Flex Rule Overview •  CMS published the final rule August 29, 2014 •  It became effec?ve October 1, 2014 •  Rule provisions: –  Allows providers to meet meaningful use with EHRs cer?fied to the 2011 or the 2014 Edi?on criteria, or a combina?on of both Edi?ons for an EHR Repor?ng Period in 2014. –  Requires providers to report using 2014 CEHRT for Repor?ng Period in 2015. –  Extends stage 2 through 2016. Stage 2 Extension Rule extends Stage 2 through 2016. Earliest a provider can begin Stage 3 is now 2017. Benefits of this extension include: •  Ensures that CMS has enough data to inform Stage 3 policy. •  Allows providers who first aRested to meaningful use in 2011 or 2012 to remain in stage 2 for an addi?onal year. •  Affords providers and technology developers with addi?onal ?me to prepare for Stage 3. 2014 Flex Rule Ø Flexibility is only available to providers who are unable to fully implement 2014 Edi?on CEHRT for an EHR Repor?ng Period in 2014 due to delays in 2014 EdiJon CEHRT availability. Ø First-­‐ year Medicaid par?cipants must use 2014 Edi?on CEHRT in order to receive a payment for adop?ng, implemen?ng or upgrading (AIU) for 2014 par?cipa?on. The Flex Rule defines that a provider’s inability to fully implement a 2014 CEHRT must be based upon: •  SoYware development delays; or •  Missing or delayed soYware updates; or •  Being able to implement 2014 CEHRT for part of the repor?ng period (not the full repor?ng period); or •  Unable to train staff, test the updated system, or put new workflows in place due to delays with the installa?on of 2014 CEHRT; or •  Cannot meet Stage 2 Summary of Care measures due to the recipient of their Summary of Care transmiRal being impacted by 2014 CEHRT issues. The sending provider may experience significant difficulty mee?ng the 10% threshold for electronic transmissions, despite the referring provider’s ability to send the electronic document, if the intermediary or the recipient of the transi?on for referral is experiencing delays in the ability to fully implement 2014 Edi?on CEHRT. The Flex Rule specifically states that the following are NOT acceptable reasons for NOT being able to fully implement 2014 Edi?on CEHRT: • 
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Financial issues. Inability to meet one or more measures. Staff turnover and change. Provider waited too long to engage a vendor. Refusal to purchase the requisite soYware. Providers who fully implemented 2014 Edi?on CEHRT and can report in 2014. Addressing Public Comments: ReporJng Ø Flex op?ons do not allow for objec?ves and measures to be mixed and matched. Ø CQMs cannot be separated from meaningful use objec?ves and measures. Ø Allowed to use updated specifica?ons. 2014 TennCare Provider IncenJve Payment Program (PIPP) Change •  Which op?ons you will be offered when you aRest for payment year 2014 will depend on the CEHRT number you enter in the EHR screen page. •  PIPP will now accept: –  2011 CEHRT, or –  2011/2014 Hybrid CEHRT, or –  2014 CEHRT* *Required prior to the CMS Flex Rule change. 2014 Flex OpJons: Stage 1 2011 CEHRT •  2013 Stage 1 objec?ves and 2013 CQMs 2011 and 2014 CEHRT •  2013 Stage 1 objec?ves and 2013 CQMs •  2014 Stage 1 objec?ves and 2014 CQMs 2014 CEHRT •  2014 Stage 1 objecJves and 2014 CQMs Selec.on in blue is not a flex op.on. 2014 Flex OpJons: Stage 2 2011 CEHRT •  2013 Stage 1 objec?ves and 2013 CQMs 2011 and 2014 CEHRT •  2013 Stage 1 objec?ves and 2013 CQMs •  2014 Stage 1 objec?ves and 2014 CQMs •  2014 Stage 2 objec.ves and 2014 CQMs 2014 CEHRT •  2014 Stage 1 objec?ves and 2014 CQMs •  2014 Stage 2 objec.ves and 2014 CQMs Selec.ons in blue are not 2014 Flex Op.ons. ONC CHPL Website: hRp://oncchpl.force.com/ehrcert?q=chpl AWestaJon Timing OpJons •  ARest at any ?me aYer repor?ng period ends – up un?l March 31, 2015 (repor?ng tail period begins January 1, 2015 and ends March 31, 2015) •  TennCare Provider Incen?ve Payment Program (PIPP) began accep?ng flex op?on aResta?ons on November 12, 2014. Flex OpJon Resources •  CEHRT Interac?ve Decision Tool-­‐ providers answer a few ques?ons about their current stage of meaningful use and Edi?on of EHR cer?fica?on, and the tool displays the corresponding 2014 op?ons. •  2014 CEHRT Flexibility Chart-­‐ chart provides a visual overview of CEHRT par?cipa?on op?ons for 2014. •  2014 CEHRT Rule Quick Guide-­‐ guide provides corresponding resources based upon the op?on a provider chooses for 2014 EHR Incen?ve program par?cipa?on. These resources are all available on the CMS EHR Educa8on Resources webpage: h=p://www.cms.gov/Regula8ons-­‐and-­‐Guidance/Legisla8on/
EHRIncen8vePrograms/Educa8onalMaterials.html Flex OpJons in PIPP: AIU Provider selects AIU. Flex OpJons in PIPP: AIU Provider enters a 2011 Edi?on CEHRT. The system will not allow this provider to aRest for payment year 2014. Flex OpJons in PIPP: AIU Provider enters a hybrid 2011/2014 Edi?on CEHRT. The system will not allow this provider to aRest for payment year 2014. Flex OpJons in PIPP: AIU Provider enters a 2014 Edi?on CEHRT and is allowed to aRest. Flex OpJons in PIPP: MU Provider selects MU. 2014 Flex OpJons: Stage 1 • 2013 Stage 1 2011 objec?ves and CEHRT 2013 CQMs Flex OpJons in PIPP: MU Provider enters 2011 Edi?on CEHRT. Flex OpJons in PIPP: MU Provider clicks OK. The provider must agree that their inability to fully implement 2014 Edi.on CEHRT was related to delays in 2014 CEHRT availability to proceed. 2014 Flex OpJons: Stage 1 2011 and 2014 CEHRT • 2013 Stage 1 objec?ves and 2013 CQMs • 2014 Stage 1 objec?ves and 2014 CQMs Flex OpJons in PIPP: MU Provider enters hybrid 2011/2014 Edi?on CEHRT. An addi?onal paragraph appears and the provider must select objec?ves and CQMs. This provider selected the 2013 objec?ves and CQMs. Flex OpJons in PIPP: MU Provider selects 2013 objec?ves and CQMs – a message appears. The provider must agree that their inability to fully implement 2014 Edi.on CEHRT was related to delays in 2014 CEHRT availability to proceed. OpJons in PIPP: MU Provider enters hybrid 2011/2014 Edi?on CEHRT. An addi?onal paragraph appears and the provider must select objec?ves and CQMs. No extra aKesta.on messages will appear. These EPs are not u.lizing the 2014 flex op.on for their meaningful use aKesta.ons. 2014 : Stage 1 • 2014 Stage 1 2014 objec?ves and CEHRT 2014 CQMs OpJons in PIPP: MU Providers who select 2014 CEHRT and are in stage 1 will see this screen. No extra aKesta.on messages will appear. These EPs are not u.lizing the 2014 flex op.on for their meaningful use aKesta.ons. 2014 Flex OpJons: Stage 2 • 2013 Stage 1 2011 objec?ves and CEHRT 2013 CQMs Flex OpJons in PIPP: MU Provider enters 2011 Edi?on CEHRT. No selec?ons are made, there is only one op?on – 2013 MU. Flex OpJons in PIPP: MU Provider clicks OK. The provider must agree that their inability to fully implement 2014 Edi.on CEHRT was related to delays in 2014 CEHRT availability to proceed. 2014 Flex OpJons: Stage 2 2011 and 2014 CEHRT •  2013 Stage 1 objec?ves and 2013 CQMs •  2014 Stage 1 objec?ves and 2014 CQMs •  2014 Stage 2 objec8ves and 2014 CQMs Selec.on in blue is not 2014 Flex Op.ons. Flex OpJons in PIPP: MU •  Stage 2 Provider enters hybrid Edi?on CEHRT. Flex OpJons in PIPP: MU Stage 2 provider must select stage and year. This provider selected Stage 1 2013 objec?ves and CQMs. Flex OpJons in PIPP: MU •  This provider selects 2013 Stage 1 objec?ves and CQMs and a message appears. The provider must agree that their inability to fully implement 2014 Edi.on CEHRT was related to delays in 2014 CEHRT availability to proceed. Flex OpJons in PIPP: MU Provider who is ready for MU Stage 2 enters hybrid 2011/2014 Edi?on CEHRT and selects 2014 objec?ves and CQMs. This provider has previously aRest to two years of S1 MU and can now must select the stage to indicate whether or not they are using the flex op?on. Flex OpJons in PIPP: MU This provider is aRes?ng to a flex op?on and selects Stage 1 MU. Flex OpJons in PIPP: MU •  When MU Stage 1 is selected the message boxes appear. The provider must agree that their inability to fully implement 2014 Edi.on CEHRT was related to delays in 2014 CEHRT availability to proceed. OpJons in PIPP: MU The Stage 2 provider who selects Stage 2 MU is not u?lizing the flex op?on. No extra aKesta.on messages will appear. These EPs are not u.lizing the 2014 flex op.on for their meaningful use aKesta.ons. 2014 Flex OpJons: Stage 2 2014 CEHRT • 2014 Stage 1 objec?ves and 2014 CQMs • 2014 Stage 2 objec.ves and 2014 CQMs Selec.on in blue is not 2014 Flex Op.on. Flex OpJons in PIPP: MU Stage 2 providers will need to select Flex OpJons in PIPP: MU •  This Stage 2 provider selects the flex op?on to aRest to 2014 Stage 1 MU. Flex OpJons in PIPP: MU Since the provider selected a flex op?on, the message boxes will appear when the OK buRon is clicked. The provider must agree that their inability to fully implement 2014 Edi.on CEHRT was related to delays in 2014 CEHRT availability to proceed. OpJons in PIPP: MU Stage 2 providers who select Stage 2 are not aRes?ng to a flex op?on. No extra aKesta.on messages will appear. These EPs are not u.lizing the 2014 flex op.on for their meaningful use aKesta.ons. OpJons in PIPP: MU No extra aKesta.on messages will appear. These EPs are not u.lizing the 2014 flex op.on for their meaningful use aKesta.ons. PIPP and Flex OpJons •  On the EHR ques?on screen, the system now checks digits 3 through 5 of your CEHRT number to determine the aResta?on selec?ons you will be offered. •  When providers select op?ons other than their normal program progression, they must aRest that they were unable to fully implement a 2014 Edi?on CEHRT due to delays in CEHRT availability. •  Providers must maintain records as to their reason for selec?ng flex op?ons as per other MU audit requirements, for 6 years. When 2014 MU is audited, if you are selected, you will have to provide these records to support your use of the flex op?on. 2014 PIPP System Changes EHR QuesJons 2011 Edi?on CEHRT New 2014 Workflow The system presents stage 1 2013 MU. Hybrid Edi?on 2011/2014 ● The system presents the provider with op?ons to choose to aRest to either Stage 1 2013 MU or Stage 1 2014 MU. ● If the provider is ready for Stage 2, the system will allow the provider to select either stage 1 or stage 2 for 2014 MU. 2014 Edi?on CEHRT ● The system presents the provider with Stage 1 2014 MU. ● If the provider is ready for Stage 2 MU, the system will allow the provider to select either stage 1 or stage 2 2014 MU. System Update Affects Some Providers Who may be affected? Providers who had aRested to the provider and EHR ques?ons but had not completed or submiRed their aResta?on for PY 2014. How will they be affected? AResta?ons in progress, were “reset” to allow those providers the opportunity to aRest for a flex op?on once the changes in the portal were complete. Technical Assistance InformaJon •  If you experience problems with or have ques?ons about the provider ques?ons, EHR ques?ons or required forms sec?ons contact [email protected] •  If you experience problems with or have ques?ons about the meaningful use screens or requirements email [email protected] Thank You!
Natalie Frady, Manager - REC (West TN) | 901-483-9624
Alicia Collins, HIT Specialist-REC (West TN) | 731-499-3516
Tabothy Edgin, HIT Specialist-REC (West TN) | 731-343-1410
Denise Satterfield, HIT Specialist-REC (Middle TN) | 615-879-8655
Christa Thompson, HIT Specialist-REC (East TN) | 865-314-4077
Patricia Pope Lead, HIT Specialist (East TN) | 423-557-3356
Jennifer Ride, Director | 615-574-7221
Visit us online at www.Qsource.org/HIT

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